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Transuranics Definition

For DOE sites.  What is your interpretation for the use of the term "transuranic" when used in 10CFR835, Appendix D, Surface Contamination Limits?



Specifically:



Is the term defined in regards to transuranic waste as cited in the DOE Radiological Control Standard DOE-STD-1089-99 ... "that is, atomic number greater than 92 AND an alpha emitter AND greater than 20 year half-life"



OR



is it defined as ANY element greater than atomic number 92.



We are looking at the appropriate surface contamination limit for PU-241.  There is a big difference based on the definition we use.



Thanks

Dave Biela



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